Case Digest: Philbag Industrial v. Philbag Workers

G.R. No. 182486 : June 20, 2012




Edwin Mauricio and Zharralyn Camacho were employees of the petitioner, Philbag Industrial Manufacturing Corporation (company), until their dismissal in the second half of 2004. Mauricio and Camacho protested their dismissal, prompting the union and the company to convene the CBAs grievance machinery in an effort to resolve the matter at plant level. Unable to reach a settlement, they agreed to have the dispute resolved through voluntary arbitration.

To avoid liability, the company maintained that both Mauricio and Camacho violated company rules on employee discipline, thereby incurring demerit points that justified their separation from the service. It pointed out that Mauricio was observed idling and wasting company time for two hours on May 24, 2004 as reported by Reinoso who witnessed the incident. With respect to Camacho, the company stressed that she failed (1) to follow the procedure in taking a leave of absence (filing the required form) or getting permission from or notifying management that she could not report for work from March 15 to 21, 2004 and (2) to have her medical certificate countersigned by the company doctor.

VA Ancheta declared Mauricio and Camachos dismissal valid. With the ruling, VA Ancheta upheld the companys prerogative to impose disciplinary action on its employees who violate company rules and regulations. The union sought relief from the CA through a petition for review under Rule 43 of the Rules of Court.

CA granted the petition and reversed VA Anchetas ruling. It found "no plausible reason for [the company] to [impose] demerit points on Mauricio and Camacho as a result of the subject incidents.

The CA thus ruled that Mauricio and Camacho were illegally dismissed. The company moved for reconsideration, which was denied by the CA.

ISSUE: Whether or not Mauricio and Camacho were illegally dismissed?

HELD: Court of Appeals decision is sustained.


Under the law, the burden of proving that the termination of employment was for a valid or authorized cause rests on the employer. Failure to discharge this burden would result in an unjust or illegal dismissal, as aptly pointed out by the CA. We find such a failure on the part of the employer in this case.

It is obvious that the company overstepped the bounds of its management prerogative in the dismissal of Mauricio and Camacho. It lost sight of the principle that management prerogative must be exercised in good faith and with due regard to the rights of the workers in the spirit of fairness and with justice in mind.

In sum, we find Mauricio and Camachos dismissal without a valid cause and, therefore, illegal.